Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00034

Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00034

January 13, 2014

Submission Number:

00034

Commenter:

Carren Kaston

State:

District of Columbia

Initiative Name:

Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163

The FTC was correct in recognizing that the merger of SCI and Stewart would harm competition in the Jewish funeral home market in the DC/MD area. However, the proposed remedy of requiring the divestiture of Edward Sagel Funeral Direction is wholly inadequate to protect competition in the market. Sagel is basically a storefront and lacks a chapel and adequate facilities to handle the deceased. It is wholly dependent on the SCI funeral home -- Danzansky -- for these services. Its market share has fallen from 25% to 11% in the last three years. If it is divested it is highly unlikely to remain an effective competitor in the market. Moreover, with the control of both Danzansky and Hines Rinaldi, SCI will still have the incentive and ability to impair the important competition provided by the Jewish Funeral Practices Committee of Greater Washington contract. I urge the Commission to revise the proposed consent decree and require the divestiture of Hines Rinaldi.